ARTICLE 21
Students and Trainees
1. (a) An individual who is a resident of a Contracting State immediately before his
visit to the other Contracting State and who is temporarily present in the other
Contracting State for the primary purpose of:
(i) studying at a university or other recognized educational institution in
that other Contracting State;
(ii) securing training required to qualify him to practice a profession or
professional specialty; or
(iii) studying or doing research as a recipient of a grant, allowance, or
award from a not-for-profit governmental, religious, charitable, scientific, artistic,
cultural, or educational organization,
shall be exempt from tax in that other State with respect to amounts referred to in
subparagraph (b).
(b) The amounts referred to in subparagraph (a) are:
(i) gifts from abroad for the purposes of his maintenance, education, study,
research, or training;
(ii) a grant, allowance, or award described in subparagraph (a) (iii); and
(iii) income from personal services performed in the other Contracting
State in an amount not in excess of 5,000 United States dollars or its equivalent in
French francs for any taxable period.
(c) The benefits of this paragraph shall only extend for such period of time as may
be reasonably or customarily required to effectuate the purpose of the visit, but in no
event shall any individual have the benefits of this Article and Article 20 (Teachers and
Researchers) for more than a total of five taxable periods.
(d) The provisions of subparagraph (a) shall not apply to income from research if
such research is undertaken not in the public interest but primarily for the private benefit
of a specific person or persons.
2. An individual who is a resident of a Contracting State immediately before his visit to the
other Contracting State, and who is temporarily present in that other State as an employee of, or
under contract with, a resident of the first-mentioned State for the primary purpose of:
(a) acquiring technical, professional, or business experience from a person other
than that resident of the first-mentioned State, or
(b) studying at a university or other recognized educational institution in the other
State,
shall be exempt from tax by that other State for a period of 12 consecutive months with respect to
his income from personal services in an aggregate amount not in excess of 8,000 United States
dollars or its equivalent in French francs.